ºÃÉ«ÏÈÉú

November 19, 2024

The Centers for Medicare & Medicaid Services (CMS) issued its 2025 Physician Fee Schedule final rule earlier this month, updating policies impacting the reimbursement of physicians under the Medicare program and highlighting the need for congressional action on certain issues.

The rule goes into effect on January 1. Visit the AAN’s detailed summary of the final rule, or keep reading for a quick guide.  

While finalized policy changes that are under CMS’s control will not change overall payments to neurology as a specialty, the rule includes a statutorily mandated cut to the Medicare conversion factor. Barring congressional intervention, this will result in an across-the-board 2.83% reduction in payment for all physician services paid under the fee schedule. Annual cuts like this one stem from the phase-out of temporary relief measures and statutory budget neutrality requirements, meaning congressional action is needed to address them.

Conversion factor cuts have a detrimental effect on the sustainability of neurological practice, and the AAN—which advocates for neurologists and their patients all year from our Washington, DC, office—is committed to payment reform efforts. We will keep working with legislators on this issue and are hopeful that Congress will address the 2025 cut in an end-of-year legislative package.

Three bills could be solutions, including the Medicare Patient Access and Practice Stabilization Act, which represents a huge step forward on the issue. Importantly, the bill would both address the cut and provide an inflationary update, increasing reimbursement under the fee schedule by a percentage of the Medicare Economic Index. Consider .

While the congressionally mandated cut may be the most widely discussed change related to the 2025 fee schedule, it isn’t the only issue calling for Congress’s attention. The Consolidated Appropriations Act of 2023 removed statutory restrictions on the provision of telehealth services, such as restrictions on geographic and originating sites, including the patient’s home, through December 31, 2024. Again, absent congressional intervention, pre-existing restrictions on site of service will go into effect on January 1 and limit the authority of CMS to pay for telehealth visits in many settings under the fee schedule.

These flexibilities are vital for neurologists and their patients, and the AAN is working with legislators to ensure their extension. Consider .

What Else Is in the Final Rule?

Although much of the policy impact stemming from the 2025 fee schedule is driven by Congress, CMS did finalize a number of policies that fall under the agency’s discretion that will have a significant impact on neurological practice.

First, CMS extended a number of other critical telehealth flexibilities, like the ability of practitioners to provide telehealth from their homes without disclosing their home address on publicly available files, through 2025. CMS is also continuing flexibilities associated with the supervision of residents and auxiliary personnel.

Representing a win for AAN advocacy, CMS will include audio-only communication in the definition of Medicare telehealth services if the patient is not capable of, or does not consent to, the use of video technology.

The agency also decided to maintain payment parity between telehealth and in-person evaluation and management (E/M) services, declining to recognize a new CPT code set for audio-only and audiovisual E/M codes for payment under Medicare. As private payers may still cover the new code, members should review their coverage policies before submitting telehealth service claims in 2025.

Other changes in the final rule include new coding and payment for caregiver training services and the implementation of Inflation Reduction Act provisions on rebates for drug price increases that outpace inflation.

Along with the detailed summary of the final rule, the AAN will offer a free member webinar on changes and updates to expect, taking place December 11 at noon CT. .